People

vs. Camat
April 2, 1996| Regalado, J. | Co-conspirators Statements
PETITIONER: People of the Philippines
RESPONDENT: Armando Rodriguez Camat (aka Amboy Camat) and Wilfredo Tanyag Del Rosario (aka Willie)

SUMMARY: Camat and Del Rosario were charged with the complex crime of robbery with homicide and frustrated homicide
for robbing and stabbing/attempting to kill Penalver and for killing Sinoy. During the police investigation, the police
investigator testified on the witness stand that Camat admitted that Del Rosario was a co-conspirator in the crime. SC held
that even though the Court could not convict Del Rosario based on Camats extra-judicial confession, there are other pieces
of evidence sufficient to sustain a conviction (i.e. Penalvers testimony).

DOCTRINE: SEE RATIO NO. 2.

FACTS:

1. Armando Rodriguez Camat (aka Amboy Camat) and
Wilfredo Tanyag Del Rosario (aka Willie) were charged with
the complex crime of robbery with homicide and frustrated
homicide.
Nelson Sinoy and Gonzalo Penalver are members of
the Philippine Marines. They were walking along
Quirino Avenue when they noticed 2 men trailing
them closely.
Sinoy and Penalver crossed the street to avoid the
men following them, but Del Rosario rushed to
Sinoy, and kicked the latter while Camat followed
Del Rosario and stabbed Sinoy.
Penalver kicked Camat, who in turn, stabbed the
former. When Penalver fell to the ground, Del
Rosario grabbed the clutch bag.
Sinoy and Penalver, despite their injuries, ran away
and were brought by a policeman to the hospital.
Sinoy died in the hospital, but Penalver survived.

2. Camat and Del Rosario interposed the defense of alibi.
Camat claimed that he was already in his house, and
before going home, he worked as a card dealer in the
saklaan. This was corroborated by his mother-inlaw, who claimed she was with Camat at the time the
latter was at home.
Del Rosario claimed that he was with his wife during
the time the crime was committed, and they sold
vegetables along a sidewalk of Quirino Ave. in
Baclaran. Upon going home, he claimed that he never
left the house again. His mother supported his story.
Both claimed they did not know each other prior to
the date of the commission of the crime.

3. Patrolman Odeo Cario, to whom the case was assigned,
testified on the following:
That Camat orally admitted to him their participation
in the killing of the soldiers. Cario also testified that
Camat gave the names of Del Rosario and a certain
person named Roland as his co-conspirators in the
crime charged.
That Camat admitted that Del Rosario was the one
who actually stabbed Sinoy.
That when he and another policeman traced the
whereabouts of Del Rosario and brought him for
questioning, Del Rosario admitted his involvement in

the crime, and that the electric tester they stole from
Penalver can be recovered from his relatives.
That they were able to identify Camat with the help of
a vendor who witnessed the incident, and said
witness identified Camat as the one who killed Sinoy.

4. The lower court found both Camat and Del Rosario guilty
of the crime of robbery with homicide and frustrated
homicide.

5. Appellants now argue that the trial court cannot reply
solely on Camats extrajudicial confession as a basis of their
conviction because it was obtained during custodial
investigation, in violation of their constitutional rights.

ISSUES:
1. W/N their constitutional rights were violated NO.
2. W/N Camats admission is binding on Del Rosario
NO.
3. W/N evidence is sufficient to support a conviction
YES.
4. W/N the appellants were deprived of their right of
confrontation when the prosecution failed to produce
the informer who allegedly pointed to/identified Camat
NO.

RULING: CA affirmed.

RATIO:
1. The lower court cannot just rely on the testimony o Camat
because there is no showing that the appellants were duly
advised of the mandatory guarantees under the Bill of Rights.

2. No reliance can be placed on the imputation therein
because it violates the rule on res inter alios acta (a thing
done between others does not harm or benefit others) and
does not fall under the exceptions thereto, especially since it
was made after the supposed homicidal conspiracy. An
extrajudicial confession is binding only upon the
confessant and is not admissible against his co-accused.
As against the latter, the confession is hearsay.

3. The testimony of a single witness, if found convincing and
trustworthy by the trial court, is sufficient to support a
finding of guilt beyond reasonable doubt.


Penalvers testimony was found to be categorical and candid,
untainted by inconsistencies, contradictions or evasions. It
creditably chronicles the material details in the commission
of the crimes in question, and should accordingly be given
full credence.

There was also no evidence of any ulterior or evil motive on
the part of Penalver that might have led him to give
fabricated testimony against the appellants. He, and even
Camat, declared in open court that they did not know each
other before the incident. And where there is no evidence
indicating that the principal witness for the prosecution was
moved by improper motive, the presumption is that he was
not so moved, and his testimony is entitled to full faith and
credit.

The appellants alibis could not also be given credence even if
they are corroborated by other witnesses. The witnesses in

this case are the mother and mother-in-law, who are

naturally expected to make statements in his favor. The
positive identification of the malefactors made by Penalver
negates appllants submissions on their respective alibis.

4. The accuseds constitutional right to meet the witnesses
face to face is limited to proceedings before the trial court.
Accordingly, appellants reliance upon this constitutional
right is misplaced as the same is available to him at the trial
and not during a custodial investigation.

It is the prerogative of each party to choose its own
witnesses in accordance with its own assessment of the
evidence it needs to prove its case. If appellants felt that the
vendor might have a grudge against Camat, there was
nothing to prevent them from determining that fact on the
witness stand by calling said vendor via compulsory process
available to them both under the Constitution and the Rules
of
Court.